Estate of Nielson 105 Cal. App. 3d 796, 165 Cal. Rptr. 319 (1980) Nielson executed a valid will. It left everything to his mother, or if she predeceased him, to a variety of charities. Nielson made a number of changes to how much $$$ went to which charity. He crossed out parts of the will and wrote new distributions in the margins. He initialed each change, then put a signature and new date in the margins. Nielson's will explicitly omitted provisions for his other relatives. Nielson died. Nielson's uncle stepped forward and challenged the will. The uncle would inherit by intestate succession if the will was found to be invalid. The Probate Court found the will to be valid. Under California State law, a holographic will must be completely in the handwriting of the testator. The uncle argued that since the will was now partially handwritten and partially typed, it was not a valid witnessed will nor was it a valid holographic will. The Appellate Court found that (assuming the handwriting was proven to be Nielson's), that the handwritten sections met the Statutory requirements of a holographic will. In addition, the handwritten holographic will authorizes an inference of an intent to incorporate by reference those portions of the typewritten will that were not crossed out. In essence, the handwritten parts and the typewritten parts should be looked at as two separate documents. The handwritten parts represent a valid codicil that refers the reader to the typewritten parts which are a separate memorandum. "The interlineations, written, signed, and dated by the testator, constitute a holographic codicil and the doctrine of incorporation by reference gave validity to republish the will as modified by the holographic codicil." The trick was that Nielson used the word "revised" showing intent. This case took place before the Uniform Probate Code came out eliminating the requirement for a holographic will to be completely in the handwriting in the testator.